CHILD SAFEGUARDING POLICY
Contents
Policy Statement: Commitment to Safeguarding Children and Guiding Principles
Scope of this Policy
Definitions
Child Safeguarding Risk Management
Establishing Risk Context
Child Safeguarding Risk Assessment
Minimum Child Protection Standards
Use of Children’s Images
Use of Social Media
Employment of Staff and Contractors
Reporting Breaches of the Global Talent Pathway Child Safeguarding Policy and Code of Conduct
Educating the Organisation
Reviewing the Child Safeguarding Policy
Resource List
Annex 1. Global Talent Pathway Child-Safe Code of Conduct
Annex 2. Reporting Framework
Annex 3. Safeguarding and Child-Safe Recruitment Practices
Annex 4. Minimum Child Protection Standards (Attachment A in DFAT Child Protection Policy 2017)
Annex 5. Global Talent Pathway Child Safeguarding Incident Reporting Form
Annex 6. Policy Objectives and Indicators
Policy Statement: Commitment to Safeguarding Children and Guiding Principles
Global Talent Pathway is committed to the safety and well-being of all children. Global Talent Pathway takes its duty of care seriously and will aim at all times to provide the safest possible environment for children. This will be achieved by identifying and managing risks that may lead to harm, and dealing immediately with concerns and reports if they arise. This policy creates clear standards for Global Talent Pathway as an organisation and for the behaviour of staff and others.
Global Talent Pathway’s Child Safeguarding Policy is based on three key pillars:
Zero Tolerance of Violence, Coercion, Exploitation, Neglect and Abuse: Global Talent Pathway believes that all children have a right to be safe at all times, and that all children have equal rights to protection from all forms of violence, coercion, exploitation and abuse, regardless of their age, gender, nationality, religious or political beliefs, family background, economic status, legal status ability, physical or mental health or criminal background. Any form of child abuse or exploitation is unacceptable. Global Talent Pathway also has a zero tolerance to inaction when a safeguarding concern or report is made.
Recognition of the International Legal Framework for Child Protection: Global Talent Pathway recognizes the United Nations Convention on the Rights of the Child (UNCRC), and its guiding child rights principles. The UNCRC is the main international human rights convention for children and Australia is a signatory country. It has four guiding principles: (1) survival and development; (2) best interests of the child; (3) non- discrimination, and (4) children’s participation. A majority of the 52 articles within the UNCRC are concerned with children’s rights to protection from all forms of violence, abuse, neglect, and exploitation.
Adherence to Child Protection Legislation: In countries where Global Talent Pathway staff and others travel and work, the Agency will adhere to local and international child protection legislation, and international laws and conventions in relation to all forms of child abuse and child exploitation, including but not limited to child sex tourism, child sex trafficking, child labour and child pornography.
Scope of this Policy
Adherence to Global Talent Pathway’s Child Safeguarding Policy and its Child Safe Code of Conduct is a mandatory requirement for all Global Talent Pathway staff, volunteers, contractors, Board members, representatives, and those visiting projects (including donors) (hereafter referred to as “staff and others”). All ‘staff and others’ engaging with Global Talent Pathway will be made aware of the child safeguarding policy and their responsibilities as stated in the policy during their orientation. This policy also applies to our overseas implementing partners (referred to as ‘partners’), their staff and subcontractors.
This policy has three key objectives:
To create and maintain protective environments for children in delivery of Global Talent Pathway activities or Global Talent Pathway funded activities.
To create mandatory organisational standards to prevent, mitigate and respond to child protection risks.
To create and enforce mandatory behavioural standards – as set out in the annexed Child Safe Code of Conduct – for all staff, volunteers, consultants, contractors, Board members, representatives, partners (including their staff and sub-contractors) and those visiting projects in order to prevent, deter and immediately respond to, risks posed to children by Global Talent Pathway and its representatives.
This policy has been reviewed to ensure compliance with the Department of Foreign Affairs and Trade (DFAT) Child Protection Policy 2017, and the Australian Council for International Development (ACFID) Code of Conduct.
Definitions:
Child: A child is any person under the age of 18 years unless a nation’s laws recognise adulthood earlier. However, for the purposes of this policy, Global Talent Pathway will always consider a child to be anyone under the age of 18, in line with the United Nations Convention on the Rights of the Child (UNCRC), to which Australia is a signatory government.
Child abuse: Abuse happens to boys and girls of all ages, ethnicity and social backgrounds, abilities, sexual orientation, religious beliefs, and political persuasion. Child abuse includes physical, sexual, and emotional abuse, neglect, ill-treatment, bullying, discrimination, child labour and domestic violence. Abuse can be inflicted on a child by men or women, as well as by other children.
Child abuse material: Material that depicts (expressly or implicitly) a child under 18 years of age as a victim of torture, cruelty, or physical abuse.
Child exploitation: one or more of the following: (1) Committing or coercing another person to commit an act or acts of abuse against a child. (2) Possessing, controlling, producing, distributing, obtaining, or transmitting child exploitation material. (3) Committing or coercing another person to commit an act or acts of grooming or online grooming. (4) Using a minor for profit, labour, sexual gratification, or some other personal or financial advantage.
Child exploitation material: Material, irrespective of its form, which is classified as child abuse material or child pornography material.
Child pornography: In accordance with the Optional Protocol to the Convention on the Rights of the Child, ‘child pornography’ means ‘any representation, by whatever means, of a child engaged in real or simulated explicit sexual activities or any representation of the sexual parts of a child for primarily sexual purposes.’
Child pornography material: Material that depicts a person, or is a representation of a person, who is, or appears to be, under 18 years of age and is engaged in, or appears to be engaged in, a sexual pose or sexual activity, or is in the presence of a person who is engaged in, or appears to be engaged in, a sexual pose or activity, and does this in a way that a reasonable person would regard as being, in all the circumstances, offensive.
Child protection: In its broadest sense, child protection is a term used to describe the field of actions that individuals, organisations, countries, and communities take to protect children from acts of maltreatment (abuse) and exploitation e.g., domestic violence, child labour, commercial and sexual exploitation and abuse, HIV, and physical violence, to name but a few.
Child safeguarding: Child safeguarding refers to the actions taken by an organisation when working with or around children to prevent and respond to the abuse of children by its own staff, volunteers or others associated with the organisation, including any partners or other contractors delivering services on behalf of the organisation. Child safeguarding is a sub-set of the broader field of ‘child protection’ (see definition above). Child safeguarding applies to any organisation that Global Talent Pathway works with, regardless of whether their activities are child-focused or not.
Child-safe environment: A child-safe environment is one where all children are protected from all forms of harm, and where there is clear, established guidelines and procedures for conduct, reporting abuse and follow-up.
Contact with children means working on an activity or in a position that involves or may involve contact with children, either under the position description or due to the nature of the work environment. This includes indirect contact with children in the community (also see ‘working with children’ below).
Discrimination: Discrimination includes the exclusion of, mistreatment of, or action against an individual based on social status, race, ethnicity, colour, religion, gender, sexual orientation, age, marital status, national origin, political affiliation, or disability.
Duty of Care: Duty of Care is a common law concept that refers to the responsibility of the organisation and individual to provide children with an adequate level of protection against harm. It is the duty of the organisation and its individuals to protect children from all reasonably foreseeable risk of or real injury.
Emotional abuse: Emotional abuse occurs when a child is repeatedly rejected or frightened by threats. This may involve name calling, being put down or continual coldness from parent or caregiver; to the extent that it affects the child’s physical and emotional growth.
Grooming: is when someone builds an emotional connection with a child to gain their trust for the purposes of sexual abuse or exploitation.
Neglect: Neglect is the persistent failure or deliberate denial to provide a child with clean water, food, shelter, sanitation or supervision or care to the extent that the child’s health and development are placed at risk.
Others: For the purposes of this policy, ‘others’, as referred to in the scope of this policy, refers to volunteers, contractors, donors, representatives, Board members, and those visiting projects overseas on Global Talent Pathway study tours.
Partner: For the purposes of this policy, Partner refers to any organisation or person that Global Talent Pathway partners with to deliver program services.
Physical abuse: Physical abuse occurs when a person purposefully injures, or threatens to injure, a child or young person. This may take any form of physical treatment including but not limited to slapping, punching, shaking, kicking, burning, shoving, or grabbing. The injury may take any form including but not limited to bruises, cuts, burns, or fractures.
Protection: Protection includes all activities aimed at ensuring respect for the letter and spirit of international human rights, humanitarian, and refugee law. For Global Talent Pathway, protection focuses on the preventing, mitigating, or responding to violence, coercion, deliberate deprivation, and abuse.
Safeguarding Focal Point: The Global Talent Pathway Safeguarding Focal Point Leads Global Talent Pathway’s safeguarding work in relation to our policy, for child and other forms of safeguarding. A specific Terms of Reference outlines this role. Within the Global Talent Pathway Child Safeguarding Policy the term ‘Safeguarding Focal Point’ refers to the Global Talent Pathway Safeguarding Focal Point unless otherwise confirmed.
Sexual abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. It covers sexual offences including but not limited to attempted rape (which includes attempts to force someone to perform oral sex); and sexual assault (which includes non-consensual kissing and touching). All sexual activity with someone under the age of consent is considered to be sexual abuse. It includes possession of child exploitation materials.
Sexual exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially, or politically from the sexual exploitation of another. Sexual exploitation includes using one’s position of authority, influence or control to pressure, force or manipulate someone to do something against their will knowingly or unknowingly, by threatening them with negative repercussions such as withholding project assistance, not approving an employee’s work support requests, threatening to make false claims about an employee in public etc.
Sexual Harassment: A person sexually harasses another person if the person makes an unwelcome sexual advance or an unwelcome request for sexual favours or engages in other unwelcome conduct of a sexual nature, in circumstances in which a reasonable person, having regard to all the circumstances, would have anticipated the possibility that the person harassed would be offended, humiliated, or intimidated. Sexual harassment can take various forms. It can be obvious or indirect, physical, or verbal, repeated or one-off and perpetrated by any person of any gender towards any person of any gender. Sexual harassment can be perpetrated against beneficiaries, community members, citizens, as well as staff and others.
Social Media: Social media refers to any form of internet or mobile phone technology, including personal websites, blogs, Facebook, Twitter, Linked In, Instagram, and others. In the context of this policy, this includes both social media used for work purposes, as well as the personal social media of staff or others.
Staff and Others: refers to all Global Talent Pathway staff, volunteers, contractors, Board members, representatives, those representing Global Talent Pathway and those participating in Global Talent Pathway-organised project visits.
Staff: Staff refers to those employed by Global Talent Pathway or contracted for work full time, part time, or casual persons working in Australia or overseas, and those engaged on short term contracts such as but not limited to consultants, researchers, photographers etc., working in Australia or overseas.
Survivor: A person who is, or has been, sexually exploited, harassed, or abused. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience, and the capacity to survive, however it is the individual’s choice how they wish to identify themselves.
Victim/survivor: A person who is, or has been, sexually exploited, harassed, or abused.
Working with Children: means being engaged in an activity with a child where the contact would reasonably be expected as a normal part of the activity and the contact is not incidental to the activity. Working includes volunteering or other unpaid work (also see ‘contact with children’ above).
Working with Children Check: is a prerequisite for anyone assessed as working with children by Global Talent Pathway. It is a state-based check which involves a national criminal history check and review of findings of workplace misconduct. The result of a Working with Children Check is either a clearance to work with children for five years, or a bar against working with children. Cleared applicants are subject to ongoing monitoring and relevant new records may lead to the clearance being revoked. If the prospective personnel have not been living in Australia or are based in a state without Working With Children Checks, they will endeavour to undertake equivalent checks.
Child Safeguarding Risk Management
Establishing Risk Context
Global Talent Pathway recognizes that there are a number of potential risks to children in its work, particularly in those programs where staff or others come into contact with children, including humanitarian response activities. In recognizing these risks, Global Talent Pathway will proactively assess and manage risks to children to reduce the risk of harm and will comply with and build on the DFAT Minimum Child Protection Standards (see Annex 4).
This includes:
In relation to Global Talent Pathway’s activities (fundraising, communication and other)
Working with partners to assess their agency and programs and identify all potential risks to children in program design and implementation.
The Global Talent Pathway Child Protection Risk Assessment tool, which is based on the DFAT Establishing Child Protection Risk Context tool, must be used by all program staff to assess:
Partners being considered for partnership
All partners and partner activities which are funded by Global Talent Pathway, whether through public or institutional fundraising.
Child Safeguarding Risk Assessment
As part of the program design and proposal appraisal process, programs staff will assess the level of risk of child harm, abuse, or exploitation, using the Child Protection Risk Assessment tool, in order to determine the level of contact with and risk to children, and the standards and mitigating measures that need to be put in place. Appropriate to the level of overall risk, this process will ensure that specific risks are identified and measures to mitigate those risks are incorporated into the program design, monitoring, and risk management.
There are generally two types of risks to children that need to be considered in the risk assessment:
Risks to children by personnel during implementation
Risk of harm to children through design or implementation of the activities.
Both types must be considered and included in the child safeguarding risk assessment and included in the project level risk management matrix and subsequent monitoring. Both types of risks should also be managed for other Global Talent Pathway activities and included in Global Talent Pathway risk management process.
Minimum Child Protection Standards
Each Partner will be assessed for their compliance with the DFAT Minimum Child Protection Standards. Planning for ensuring Partners are meeting these standards will be documented in Partner Plans, reviewed in the regular review process for Partner Plans, and reflected in risk management and monitoring procedures.
Global Talent Pathway’s compliance with these Minimum Standards is regularly monitored and is reported in Global Talent Pathway risk management processes.
In addition, in emergency settings, the Minimum Standards for Child Protection in Humanitarian Action (CPMS) should be applied whenever possible.
Use of Children’s Images
Global Talent Pathway marketing and fundraising material will at all times portray children in a respectful, appropriate, and consensual manner. Guidelines on the use of children’s images are included in ANNEX 1 Child Safeguarding Code of Conduct.
Use of Social Media
Global Talent Pathway staff often use social media, both for work purposes as well as privately. The same guidelines for the use of children’s images outlined in Global Talent Pathway’s Child Safeguarding Code of Conduct apply to images and video posted on work-related social media. Staff will at all times uphold the values and beliefs of Global Talent Pathway when using work-related social media. Under no circumstances are staff members, volunteers, or others to use photos or videos of children taken during a work trip on their personal social media sites or for purposes other than that intended and/or agreed. Unless required by the program, communicating privately with beneficiaries met during a field visit is not allowed. Staff and others must never communicate through their own personal email, Facebook, or other social media accounts with any beneficiaries under the age of 18.
Employment of Staff and Contractors
Global Talent Pathway is committed to preventing a person from working with children if they pose an unacceptable risk to children. Global Talent Pathway’s commitment to child safe recruitment, selection and screening practices aims to recruit the safest and most suitable people to work in our programs. Global Talent Pathway has robust recruitment screening processes for all personnel in contact with children and additional screening measures for positions working with children. Our child safe recruitment practices are included in ANNEX 3.
The Child Safe Code of Conduct (Annex 1) outlines acceptable and unacceptable behaviour in relation to children. Global Talent Pathway requires all staff to comply with the Child Safeguarding Policy and Child Safe Code of Conduct throughout their period of employment with Global Talent Pathway. Failure to do so may result in a transfer to other duties, suspension, or dismissal, depending on the nature of the offense. Criminal behaviour will be immediately reported to the proper authorities.
Reporting Breaches of the Global Talent Pathway Child Safeguarding Policy and Code of Conduct
Staff and others must immediately report any behaviour that is suspected of being:
child exploitation, harassment, or abuse, including possession of child exploitation material.
breaches of Child Safeguarding Policy or Code of Conduct.
Global Talent Pathway has a zero tolerance to inaction when a safeguarding concern or report is made.
Concerns and reports can be provided direct to Global Talent Pathway Safeguarding Focal Point in the following ways:
in-person to the Global Talent Pathway Safeguarding Focal Point
via email at childprotection@globaltalentpathway.org
by phoning the Sydney office on 1300 191 630, and speaking to the Safeguarding Focal Point
The Global Talent Pathway Child Abuse Incident Reporting Form is available in ANNEX 5.
Concerns and reports can also be provided via Stopline, an external complaints and whistleblowing service engaged by
Global Talent Pathway to support safe handling of complaints and investigations.
Via email at childprotection@globaltalentpathway.org
via phone on: Australia: 1300 191 630
Community members can also use these same contact details to report breaches or concerns.
Confidentiality of Reporting
All information about child safeguarding concerns and reports is to be kept confidential. Reports are to be made directly to the Safeguarding Focal Point who will coordinate an investigation team as appropriate. The Chief Executive Officer is to be notified by the Safeguarding Focal Point immediately that a report has been received. The Chief Executive Officer will notify the Board’s Safeguarding representative, the Chair of the Global Talent Pathway Board and the Chair of the Finance, Audit and Risk Management Committee. The Safeguarding Focal Point is to update the Chief Executive Officer on progress with the investigation, to ensure that documentation is kept in a secure file. Reports can be made by staff and others and by any external party. If the safeguarding concern is regarding one of the nominated individuals listed to be notified, they will be excluded from the chain of reporting and investigation team.
The Global Talent Pathway Safeguarding Focal Point must immediately (same working day) report to DFAT any behaviour that is suspected of being child exploitation or abuse or policy non-compliance by:
Global Talent Pathway personnel (staff and others) or for an Global Talent Pathway partner funded by DFAT, including subcontractors.
A DFAT staff member or employee of another Commonwealth Government Agency
Any Australian citizen, Australian permanent resident, or Australian company.
If an Global Talent Pathway staff member is unsure whether a concern or allegation amounts to child exploitation or abuse or a breach of policy/code of conduct, they must contact the Global Talent Pathway Safeguarding Focal Point for confidential advice and further information by sending an email to childprotection@globaltalentpathway.org, or by phoning the Sydney office on 1300 191 630, and speaking to the Safeguarding Focal Point.
If the Global Talent Pathway Safeguarding Focal Point is unsure whether an allegation should be reported to DFAT, rather than drawing their own conclusion, the Global Talent Pathway Safeguarding Focal Point will contact the DFAT Conduct and Ethics Unit at the following email address:
Email: childwelfare@dfat.gov.au
Queries regarding application of the DFAT Child Protection Policy will be directed to the DFAT Child Protection Compliance Section on Telephone: +61 2 6178 5100.
While noting that any investigation needs to be conducted thoroughly, in such a way as to best address risk, and in consultation with DFAT, all efforts should be made to complete investigations within 60 days in order that a final report to DFAT may be promptly submitted. Any actions necessary to meet the protection needs or the mental and physical health needs of the child MUST be taken at the same time that any reporting and/or follow-up investigation is taking place.
If an Global Talent Pathway staff member is requested not to take any further action by the person making the allegation, for instance out of fear for the security of the child, the Global Talent Pathway staff member must advise the requesting person that they are still obliged to notify Global Talent Pathway Safeguarding Focal Point and will pass on the protection concern. If the allegation is reportable to DFAT under the DFAT policy, the Global Talent Pathway Safeguarding Focal Point must still notify DFAT acknowledging the security concern.
Having provided initial, immediate notification to DFAT, Global Talent Pathway’s Safeguarding Focal Point must seek to ensure that any missing details are obtained and then provided to DFAT within 14 days.
If the incident occurred in Australia and constitutes illegal activity or if a child is in danger, immediately notify the Police and other relevant authorities such as the Department of Community Services. Contact details will vary based on the location of the incident, but the New South Wales police can be contacted on https://www.police.nsw.gov.au/contact_us. Further guidance is to be sought from the Police on other agencies to contact.
If the incident occurred outside Australia and constitutes criminal behaviour, contact Australian Federal Police if it concerns an Australian citizen.
In certain circumstances there may be an obligation to disclose to other relevant donors (In addition to DFAT).
Delegation schedule: If the Global Talent Pathway Safeguarding Focal Point is on leave or otherwise un-contactable, the Partnerships and Programs Safeguarding Representative, or, if unavailable, the Global Talent Pathway Chief Executive Officer, will be the acting Global Talent Pathway Safeguarding Focal Point.
Educating the Organisation
Global Talent Pathway is committed to providing child safeguarding training for all staff and others. The child safeguarding policy is included in the orientation procedures for all new staff. All staff attend regular Child Safeguarding training sessions. The Head of Operations, Safeguarding Focal Point, Partnerships and Programs Safeguarding Representative, Marketing and Communications Safeguarding Representative, Policy and Program staff and Marketing staff responsible for use of images and social media will be encouraged to attend training on child safeguarding policies and practices provided by recognised external agencies.
The policy will be made available to all staff and others and will be incorporated into Global Talent Pathway’s Policy Manual, Operations Manual and Quality and Accountability Monitoring Matrix.
All staff and others will sign and acknowledge understanding of the Child Safeguarding Policy and Code of Conduct as a requirement of recruitment/engagement.
Reviewing the Child Safeguarding Policy
Global Talent Pathway’s Child Safeguarding Policy will be reviewed every three years or earlier if required by changes occurring in Global Talent Pathway, DFAT, ACFID, State or National Legislation or international law. The Global Talent Pathway Safeguarding Focal Point will manage the review of the Child Safeguarding Policy in consultation with staff and Senior Management. The policy will be accessible on our website at all times.
Resource List
DFAT Child Protection Policy 2017 and DFAT Child Protection Guidance Notes: http://dfat.gov.au/about- us/publications/Pages/child-protection-policy.aspx
United Nations Convention on the Rights of the Child: https://www.unicef.org/crc/
Minimum Standards for Child Protection in Humanitarian Action. Child Protection Working Group (2012): https://acfid.asn.au/sites/site.acfid/files/resource_document/CP-Minimum-Standards.pdf
ECPAT International http://www.ecpat.org/
IASC Child Protection Thematic area guide for : Integrating gender-based violence interventions in Humanitarian Action: http://gbvguidelines.org/wp-content/uploads/2015/09/TAG-child-protection-08_26_2015.pdf
Keeping Children Safe - A toolkit for child protection: http://resourcecentre.savethechildren.se/library/keeping- children-safe-toolkit-child-protection
Setting the standard – A common approach to Child Protection for international NGOs: https://resourcecentre.savethechildren.net/sites/default/files/documents/1603.pdf
United Nations World Report on Violence Against Children: www.unviolencestudy.org
ACFID Guidelines for development of a child protection policy: https://acfid.asn.au/sites/site.acfid/files/resource_document/Guidelines-for-the-development-of-a-child- protection-policy.pdf
The Crimes (Child Sex Tourism) Amendment Act (1994)
Keeping Children Safe Online: https://acfid.asn.au/sites/site.acfid/files/resource_document/KCS_Online_Guidance_2014.pdf
UNICEF, Child Protection in the Digital Age: National responses to online child sexual abuse and exploitation in ASEAN Member States (2016): https://www.unicef.org/eapro/Child_Protection_in_the_Digital_Age.pdf
UN Convention on the Rights of the Child In Child Friendly Language: Poster and brochure
IAWGCP, Children's Participation in Decision Making: Why do it, when to do it, how to do it (2007)
Annex 1. Global Talent Pathway Child-Safe Code of Conduct
Note: This Code of Conduct is to be read in conjunction with Global Talent Pathway Child Safeguarding Policy
Staff, volunteers, contractors, and others representing or visiting Global Talent Pathway projects are responsible for maintaining a professional role with children, which means establishing and maintaining clear professional boundaries that serve to protect everyone from misunderstandings or a violation of the professional relationship. This Safeguarding Code of Conduct sets out the behaviour which Global Talent Pathway expects from all people associated with or representing it and should be read in conjunction with the Global Talent Pathway Code of Conduct.
Global Talent Pathway condemns all forms of child abuse, discrimination, and sexual exploitation, and is committed to creating and maintaining a child-safe environment. Child abuse occurs when adults or other children hurt children or young people under the age of 18, either physically, emotionally, sexually, through neglect, or in some other way.
I, , acknowledge that I have read and understand Global Talent Pathway’s Child Safeguarding Policy, and agree that in the course of my association with Global Talent Pathway,
I WILL:
Conduct myself in a manner that is consistent with the values of Global Talent Pathway.
Treat all children and young people with respect, regardless of race, colour, sex, language, religion, political or other opinion, national, ethnic, or social origin, property, disability, birth, or other status.
Provide a welcoming, inclusive, and safe environment for all children, young people, parents, staff, and volunteers.
Keep confidential all information that I am a party to regarding child protection cases, disclosing and discussing information only with the Head of Operations, the Safeguarding Focal Point or other parties as designated by them and/or according to reporting procedures.
Respect cultural differences.
Encourage open communication between all children, young people, parents, staff, and volunteers, and allow children and young people to participate in the decisions that affect them.
Report any concerns of child abuse in accordance with Global Talent Pathway reporting procedures.
Be transparent in my actions and whereabouts.
Take responsibility for ensuring I am accountable and do not place myself in positions where there is a risk of allegations being made. Wherever possible, I will ensure that another adult is present when I am working in the proximity of children. I will discuss other measures as necessary with the Global Talent Pathway Safeguarding Focal Point.
Self-assess my behaviour, actions, language, and relationships with children.
Report any concerns or suspicions regarding abuse by a fellow worker, volunteer, contractor, consultant, visitor, or partner personnel via Global Talent Pathway child safeguarding incident reporting mechanisms.
Comply with all relevant Australian and local legislation, including labour laws in relation to child labour.
Immediately disclose all charges, convictions and other outcomes of an offence that relates to child exploitation and abuse, including those under traditional law, which occurred before or occurs during association with
Global Talent Pathway Code of Conduct including prevention of sexual exploitation and abuse, all forms of harassment, fraud and corruption, security breaches, unethical business practices and other abuses of power.
Immediately report concerns or allegations of children exploitation and abuse and policy non-compliance in accordance with appropriate procedures
I WILL NOT:
Engage in behaviour that is intended to shame, humiliate, belittle, or degrade children.
Use inappropriate, offensive, harassing, abusive, sexually provocative, demeaning, culturally inappropriate or discriminatory language when speaking with a child or young person.
Invite unaccompanied children into my home unless they are at immediate risk of injury or in physical danger.
Hit or physically assault children. This includes refraining from physical punishment or physical discipline of children.
Develop sexual relationships with children or relationships with children that may be deemed exploitative or abusive.
Engage in any form of sexual activity or acts, including paying for sexual services or acts, with any child under the age of 18.
Behave provocatively or inappropriately with a child. Hold, kiss, cuddle or touch a child in an inappropriate, unnecessary, or culturally insensitive way.
Do things of a personal nature that a child can do for him/herself, such as assistance with toileting or changing clothes. If this is necessary, for example for a child with a disability, I will inform my supervisor first and be as open as possible in my behaviour.
Sleep close to unsupervised children unless absolutely necessary, in which case I must obtain my supervisor’s permission, and ensure that another adult is present if possible.
Seek to make contact and or spend time with any child that I come into contact within my role as a representative of Global Talent Pathway outside of the designated times and activities set for performing my role as a representative of Global Talent Pathway*. This includes not making contact by email or social media. I will not seek to connect with or “friend” any children I meet in the field on my personal social media account, including Facebook or any other social media platform.
Show favouritism through the provision of gifts or inappropriate attention.
Supply or provide anyone under 18 with alcohol or illegal drugs.
Condone or participate in behaviour of children that is illegal, unsafe, or abusive.
Act in a way that shows unfair and differential treatment of children.
Release or discuss any personal or confidential information about suspected or proven child abuse or protection cases other than with the Chief Operation Officer, the Safeguarding Focal Point or the Chief Executive Officer of Global Talent Pathway and other parties as designated by them and according to reporting procedures.
Use any computer, mobile phone, or video and digital camera to exploit or harass children. I will not access child exploitation material (including child pornography) through any medium (see also ‘Use of Children’s Images’ below)
Hire children to perform domestic labour or other labour, which is inappropriate given their age or developmental stage, which interferes with their time available for education and recreational activities, or which places them at significant risk of injury.
Use of Children’s Images
When photographing or filming a child for work purposes, I must:
Not post photos taken of children during a field visit on any of my personal social media sites (Facebook, Twitter, Instagram, blog, website, etc.)
Assess and endeavour to comply with local traditions or restrictions for reproducing personal images before filming or photographing a child.
Obtain informed consent from the child and parent or guardian before taking a child’s photography or filming them. As part of this I must explain how and where the photograph or film will be used and for what purpose. I will use the Record of Informed Consent For Use of Images Form, found in the Global Talent Pathway Guidelines for the Collection, Storage and Use of Images which is saved in the same SharePoint folder as the Operations Manual, to record all details of the image taken. If culturally appropriate, I will ask the parent to sign the Consent Form, otherwise I will ask for verbal consent and then sign the form myself. This form will be kept on file at the Global Talent Pathway office as important evidence that consent has been sought and given.
Ensure photographs or films present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive.
Ensure images are honest representations of the context and the facts.
Ensure children are portrayed as part of their community.
Ensure file images, file labels, meta data, or text descriptions, do not reveal identifying information about a child when sending images electronically.
Ensure there is no identifying information of the child used in the publication of images with their location. I will ensure all recorded identifying details are stored confidentially.
Ensure all photographers I am supervising are screened for their suitability, including police checks.
Ensure a risk assessment is conducted before live streaming, expectations of privacy are considered, and the same principles outlined above are applied.
These behaviours are not intended to interfere with normal family interactions.
I understand that the onus is on me, as a person engaged or associated with Global Talent Pathway, to use common sense and avoid actions or behaviours that could be construed as child abuse when engaging in Global Talent Pathway activities or visiting Global Talent Pathway projects.
I have read the Global Talent Pathway Child Safeguarding Policy and Code of Conduct. I am aware that Global Talent Pathway expects me to uphold at all times the standards of behaviour described in the Code of Conduct above. I also understand that disciplinary measures and legal steps will be taken if I am found to be in breach of the Code of Conduct. I understand that in making this report, Global Talent Pathway may have to inform other authorities, in a confidential manner and only if necessary for the safety of the child, the staff member, or the agency, or to meet obligations to DFAT or under Australian law.
Name of signatory:
Signature:
Date:
Name of Witness:
Signature:
Date:
Annex 2. Reporting Framework
If you are concerned about the safety of a child: (1) If you see or suspect abuse. (2) If an allegation of abuse is made. (3) If a child discloses abuse.
Report concerns immediately (same day) to the Safeguarding Focal Point – childprotection@globaltalentpathway.org
You should also notify your line manager (unless this person is at the centre of your concerns).
The Safeguarding Focal Point can support you in reporting, and discussions should focus on: nature of concerns, risks to children, action/next steps.
Ensure detailed written records are made of all events and what the child has said in their own words (where this applies).
DFAT must also be informed on the same working day (the Safeguarding Focal Point will file the report) childwelfare@dfat.gov.au
Where serious concerns exist and there is immediate risk to the child: TAKE ACTION!
It is essential to avoid delay as inaction may place the child at further risk
Where for any reason it is not possible to discuss the matter with the Global Talent Pathway Safeguarding Focal Point, contact the Chief Executive Officer.
Where immediate action is essential due to risk to the child, the Safeguarding Focal Point should be informed as soon as possible after the event.
Annex 3. Safeguarding and Child-Safe Recruitment Practices
Global Talent Pathway engages the safeguarding and child safe recruitment procedures outlined below, which are further detailed in the Operations Manual.
In position descriptions and advertisements:
Position descriptions are provided for all staff and others engaged to work for Global Talent Pathway which describe key selection criteria and outline tasks and accountabilities, including PSEAH responsibilities/obligations.
All positions, including where the duties of an existing position are changed, are assessed for level of contact with children and level of risk in relation to contact with children. Subsequent actions will then be required accordingly. Positions can be assessed as: (1) No impact on/no contact with children, (2) Impact on/contact with children (3) Working with children .
The PSEAH Minimum Standards (see PSEAH Policy) are applied commensurate with the level of risk identified.
Our child safe commitment and commitment to PSEAH is promoted on our website and in all job advertisements.
Our website link to the child safeguarding policy and PSEAH policy is provided to all job applicants.
Applicants will be requested to disclose whether they have been charged with child exploitation offences and/or other sexual exploitation, abuse, or harassment offences in Australia or overseas in the application process. This will be documented.
In interviews and referee checks:
Interviews are conducted for all positions, ideally in-person, but skype video interviews may be necessary in the international context.
In all interviews: behavioural-based questions are included, asking for examples of the candidate’s past behaviour and experiences.
In positions assessed as working with children, the panel will also explore the candidate’s motivations for and experience in working with children, including value-based and scenario-based questions seeking information about the candidate’s attitudes to children, professional boundaries, accountability, teamwork, how they have responded to ethical dilemmas and past behaviours and responses to certain situations. This includes existing staff within the organisation, who are applying internally, as well as staff and consultants recommended by other organisations.
A minimum of two verbal reference checks are required for all preferred candidates, including short- and long-term positions, volunteers, interns, and consultants representing Global Talent Pathway. The candidate’s most recent employer/supervisor must be one of these referees. Global Talent Pathway will verify the identity of the referee and make direct contact with each of these referees. Written references will not be accepted. Global Talent Pathway reserves the right to request additional references. Unless the position is assessed as no impact on/no contact with children, the reference check will include a child safeguarding question. Unless the position is assessed as low/med risk of SEAH, the verbal reference check will include a screening question for SEAH.
The Safeguarding Focal Point is to assess all new position descriptions and will provide training or other support to managers altering existing position descriptions.
In contracts:
All positions include a probationary period (depending on the length of the contract).
Global Talent Pathway reserve the right to refuse employment to or terminate any person’s employment if they may pose a risk to children or adults. All employment contracts, including for consultants, must contain provisions for disciplinary action up to and including dismissal for any person who breaches the Child Safeguarding Policy and Child Safe Code of Conduct, or the PSEAH Policy and Global Talent Pathway Code of Conduct.
Upon accepting a job offer:
Before engagement, all staff, and others unless in positions assessed as having no impact on/no contact with children or low/med risk of PSEAH, must provide an Australian Federal Police Check or a relevant criminal history check (this may depend on the country or countries of most recent residence).
All staff and others must sign Global Talent Pathway’s Code of Conduct and Child Safeguarding Code of Conduct to acknowledge they have read, fully understood, and agree to comply with, Global Talent Pathway’s PSEAH Policy and Child Safeguarding Code of Conduct.
Staff and others in positions assessed as working with children, and who have worked in Australia, must provide a Working with Children Check or equivalent as allowed by legislation. Once engaged, all staff and others will receive an induction that includes PSEAH and Child Safeguarding orientation and attend regular Child Safeguarding and PSEAH training sessions.
Global Talent Pathway Schedule for confirming Compliance Requirements
See Table 1, next page. Requirements are based on:
Legislative requirements
Global Talent Pathway policy requirements
An assessment of level of contact with children and level of risk in relation to contact with children.
As assessment of level or risk of SEAH.
Note: Working With Children Checks and National Police Checks to be updated every 5 years.
Checks must be conducted for each country in which the individual has lived for 12 months or longer over the last 5 years, and for the individual’s countries of citizenship.
Table 1: Global Talent Pathway Schedule for confirming Compliance Requirements
Annex 4. Minimum Child Protection Standards (Attachment A in DFAT Child Protection Policy 2017)
The Table in Annex 4 is a reference table from DFAT’s Child Protection Policy 2017.
Annex 5. Global Talent Pathway Child Safeguarding Incident Reporting Form
Global Talent Pathway will take all concerns and reports of child abuse, exploitation, or harassment seriously and immediate action will be taken. Staff members or others reporting child safeguarding concerns will be supported by Global Talent Pathway throughout the process of assessing the claim. A framework for reporting is in Annex 2 of the Global Talent Pathway Child Safeguarding Policy.
This form should be used to report if you see or suspect abuse, exploitation, or harassment, if an allegation of abuse, exploitation or harassment is made, or if a child discloses abuse, exploitation, or harassment. The information you provide here will be kept CONFIDENTIAL and all steps will be taken to ensure you are supported by management and that your protection is considered in any actions taken.
Part One: About You
Name:
Your role in (Global Talent Pathway):
Details of any other organisation involved: Your relationship to the child or young persons concerned:
Part Two: About the Child
Name(s): Male/female:
Age:
Address:
Whom does the child or young person live with?
Part Three: About Your Concern(s)
How did you come to have a concern: was the abuse, exploitation or harassment observed or suspected? Was an allegation made? Did a child disclose abuse, exploitation, or harassment?
Date, time, and place of any incident(s) reported to you: Nature of concern/allegation:
Observations made by you (e.g. child’s emotional state, any physical evidence):
Write down exactly what the child said and what you said (or another informant said):
(continue a separate sheet of paper if necessary)
Any other relevant information? (E.g. disability? language?) Were other children involved or aware?
Are other children in immediate danger or at risk?
Have you already spoken to parents or carers or any other Child Protection Personnel or Agencies? Yes or No
If yes, who or whom? Time and date that report was submitted:
Person(s) to whom report was made:
(e.g. name of supervisor/manager/staff)
Advice given by that person or agency:
Action taken: Signed
Date
Note: Please remember that all information contained in this report must be kept confidential and must not be revealed to anyone except the person you reported to. You will be informed of next actions that will be taken.
Annex 6. Policy Objectives and Indicators
Objectives | Indicators | Actions |
---|---|---|
1. To create mandatory pro- active organisational standards for to prevent, mitigate and respond to child protection risks. | Global Talent Pathway Child Safeguarding Policy reflects best practice, sectoral standards, and its obligations to ACFID, DFAT, ACT Alliance | CS Policy reviewed every three years or as needed to mitigate risks |
2. To create and enforce mandatory behavioural standards – in the annexed Child Safe Code of Conduct – for all staff, volunteers, contractors, donors, Board members, representatives, and those visiting projects in order to effectively prevent, deter and respond immediately to, risks posed to children by Global Talent Pathway and its staff and/or any partners or contractors that Global Talent Pathway engages to provide services. | Global Talent Pathway’s zero-tolerance approach, obligations, and expectations for the behaviour of staff and others are made know to all Global Talent Pathway stakeholders | CS Policy permanently available on Global Talent Pathway’s website All new staff and others are provided orientation on child protection. Annual refresher sessions will be provided at staff meetings. All staff will sign and acknowledge understanding of the Child Safeguarding Policy and Code of Conduct, and HR keeps a register of all signatories. Records are maintained by MAC to demonstrate informed consent for use of images. |
Child-safe recruitment and interviews occur | All job advertisements contain Global Talent Pathway’s standard child safeguarding text. All interviewees are told of Global Talent Pathway commitment to child safeguarding (standard question in Interview Template All interviewees that will be in contact with children are asked behavioural child protection questions in their interview. All staff and others have had mandatory police checks and HR keeps register of checks completed. All staff and others that have worked in Australia and will be working with children will have a Working With Children Check, and HR keeps a register of checks completed. |
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Global Talent Pathway ensures its partners have effective CS policies and procedures to prevent, mitigate and respond to CS risk, reports, and incidents | All partners have Global Talent Pathway- approved CS policies. Global Talent Pathway partner and grant agreements contain Global Talent Pathway CS clauses. Partner and Project Risk Assessment undertaken and activities to mitigate risks taken and recorded: Program and Policy Team members will conduct a child safeguarding audit with their partners once every year |
PPT completes Child Safeguarding Risk Assessment tool with partners before or at proposal appraisal, including full risk assessment where indicated and ongoing monitoring at reporting. |
Requirement | Minimum standard | Minimum standard – evidence | Why is this required? | What is the risk without it? |
---|---|---|---|---|
Having a Child Protection Policy and reporting procedure in place | 1. The organisation has a child protection policy that applies to all personnel, partner's downstream personnel and subcontractors that are engaged by the organisation to perform any part of a DFAT funded activity. That managing partner must ensure the downstream organisation or individual subcontractor compiles with the minimum child protection standards |
- Child protection policy in place - Personnel aware of the organisation's child protection policy (e.g. through internal communication and training) - Documented plan for ensuring downstream DFAT funded pertners are meeting the minimum standards. - Initial risk assessment of organisation and activities to inform policy development |
A chiild protection policy provides clear guideance and demonstrates how the organisation, across its operations, will ensure that children are protected from child exploitation and abuse in the delivery of DFAT administered/ funded programs. | An organisation is unaware of the risks to children within their organisation and the activities they manage and/or implement. Having a sub-contractor sign up to a code of conduct as the only control does not provide sufficient contractual effect to address child protection issues. |
2. The organisation’s child protection policy includes a documented reporting procedure for child exploitation and abuse allegations, code of conduct and policy non-compliance, including available sanctions for breaches. | - Organisation’s guidelines for managing concerns or allegations of child exploitation and abuse, and policy non-compliance. - Documentary evidence that personnel can raise concerns about a child’s safety or well-being or unacceptable behaviour by personnel. - Documentary evidence outlining the organisation’s details of available sanctions. - Documentary evidence of externally facing policy and reporting information |
An effective child protection policy requires a report handling procedure. One of the biggest hurdles to personnel reporting child exploitation and abuse is that there is no formal system in place to do so, or that personnel or community members are not aware of a formal system to report concerns or allegations. Reporting systems must respect the rights of both the alleged victim and the alleged offender. |
Personnel are unaware how to report concerning behaviour. Community members are unaware how to report concerning behaviour. |
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3. The organisation provides child protection training for personnel. | - Training attendance records - Training agendas and timeframes for training - Materials used in training |
Personnel must be fully aware of their responsibilities to protect children and how to report concerns or allegations about child exploitation and abuse. | Personnel are unaware of behaviour that would arouse concern. Personnel are unaware of how to build child protection practices into their work. Personnel do not know how to report concerning behaviour. |
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4. The organisation’s child protection policy includes a commitment to preventing a person from working with children if they pose an unacceptable risk to children | - Referenced in relevant documentation, including policies, contracts, and human resource guidelines | The organisation, as an employer, must have clear grounds to determine whether a person is the most appropriate to work with children. | A lack of leadership and governance and the right culture undermine personnel efforts to implement a child protection environment. | |
5. The organisation’s child protection policy is subject to regular review, at least every five years or earlier if needed. | - Policy is subject to regular review in accordance with the policy commitment, or at least every five years. | Contexts change, particularly in the development sector. There must be a commitment to review and update the policy as required. | Lessons learned from previous incidents are not taken into account, increasing the likelihood that those risks will be repeated. | |
Undertaking risk assessment | 6. The organisation undertakes a risk assessment to reduce the risk of any child being harmed as a result of operations or activities funded by DFAT. The assessment must identify risks, and document steps being taken to reduce or remove these risks. | - Risk plan identifying activities and measures to reduce or remove the risk to children. - Documentation that risks assessments are reviewed and updated regularly during the life of the activity. - Evidence of adaption to local context (when a different approach to standard risk controls is required |
Some activities are higher risk than others. This may be due to the nature of the activity or the location. For example, working with children with disability or in an emergency situation involve higher risks. | Risks to children are missed during activity design and implementation. |
Recruitment and screening, and employment practices in place | 7. The organisation's employment contracts contain provisions for suspensions or transfer to other duties of any employee who is under investigation and provisions to dismiss any employee after an investigation. | - Employment contracts for personnel/ consultants contain appropriate provisions | Robust recruitment, screening and employment practices reinforce the importance of the organisation’s child protection policy to personnel. | Personnel that pose unacceptable risks to children are unable to be removed (suspended, transferred, or terminated) without a criminal conviction, where contracts are in place. |
8. a. Positions assessed as Contract with children. The organisation has robust recruitment screening processes for all personnel in contact with children. These recruitment procedures includes: - Criminal record checks before engagements -Verbal referee checks b. Position assessed as Woring with children. Additional screening measures (such as interview plans that incorporate behavioural-based interview questions) must be used when candidates are applying for positions that involve working with children. |
- Documented criminal record checks for personnel in contact with children. - Documented verbal referee checks - Documented request for an applicant to disclose whether they have been charged with child exploitation offences, and their response. - Interview plans incorporating behavioural-based interview questions that are specific to positions that involve working with children. - Review checks when personnel have a change in circumstances. - In limited circumstances it may prove impossible to obtain a reliable criminal records check. A statutory declaration, or local legal equivalent, outlining efforts made to obtain a foreign police check, and disclosing any charges and spent convitions related to child exploitation, may be accepted instead. - Checks must be conducted for each country in which the individual has lived for 12 months or longer over the last 5 years, and for the individual's countries of citizenship |
Child-safe recruitment and screening processes are essential to enable an organisation to choose the most appropriate person for a position that involves contact with children. Recruitment and selection can strengthen external inhibitors by preventing access to children by those with a known history of harming children. Child safe recruitment and selection processes can discourage individuals who pose an unacceptable risk to children from applying for positions. |
Adults with a background of unacceptable risks to children target organisations that will provide opportunities to be in contact with children. A person who poses an unacceptable risk of harm to children (as indicated by their background) is unknowingly appointed to a position within the organisation. |
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9. The organisation has a child protection code of conduct that meets the minimum standard set by DFAT (see Attachment B – DFAT’s Child Protection – Professional Behaviours). | - A risk-based child protection code of conduct based on DFAT’s Child Protection – Professional Behaviours - Signed codes of conduct or a register documenting details of personnel who have signed the code of conduct, or inclusion in employment contracts. - Signed image consent forms/ verbal consent file notes. |
A code of conduct makes clear the organisation’s standards for acceptable and unacceptable behaviour in relation to children, including use of images and must be signed by all personnel. It protects personnel by providing guidance on how to avoid situations that may be perceived as harmful to children. It also provides employers with a sound basis on which to conduct disciplinary action. |
Lack of clear, well-advertised rules allows concerning behaviour to go unchallenged. Identification of a child and/or their whereabouts. |
Directors | Permanent Staff (full time and part time) | Casual Staff | Volunteers, including interns | Consultants/Contractors | Others | |
---|---|---|---|---|---|---|
Verbal Referee Checks conducted (at least 2) | All | All | Those volunteering with Global Talent Pathway in a role assessed as having contact with or working with children. Those in positions assessed as nil contact with/nil impact on children are exempt | All except those in positions assessed as nil contact with/nil impact on children | NA | |
Contract inclusions | A commitment to preventing a person from working with children if they pose an unacceptable risk to children. Provisions for disciplinary action up to and including dismissal for any person who breaches the Child Safeguarding Policy and Child Safe Code of Conduct. | A commitment to preventing a person from working with children if they pose an unacceptable risk to children. Provisions for disciplinary action up to and including dismissal for any person who breaches the Child Safeguarding Policy and Child Safe Code of Conduct. | A commitment to preventing a person from working with children if they pose an unacceptable risk to children. Provisions for disciplinary action up to and including dismissal for any person who breaches the Child Safeguarding Policy and Child Safe Code of Conduct. | For those in positions assessed as in contact with or working with children, the contract must include clauses ensuring the contractor takes appropriate measures to ensure child safeguarding. A commitment to preventing a person from working with children if they pose an unacceptable risk to children. Provisions for disciplinary action up to and including dismissal for any person who breaches the Child Safeguarding Policy and Child Safe Code of Conduct | ||
Signed Global Talent Pathway Code of Conduct | All | All | All | Those volunteering with Global Talent Pathway for longer than a week, or on a sporadic, long- term basis (regular volunteers on the speaker’s network, interns, etc.) | Those representing Global Talent Pathway (project evaluators, call centre staff etc.) | All visiting projects |
Signed Global Talent Pathway Child Safeguarding Code of Conduct | All | All | All | All | All except those in positions assessed as nil contact with/nil impact on children | All except those in positions assessed as nil contact with/nil impact on children |
National criminal records check | All | All | Those whose positions is assessed as either contact with or working with children to have for all countries of citizenship and countries of residence for last 5 years | Those whose positions is assessed as either contact with or working with children to have for all countries of citizenship and countries of residence for last 5 years | Those consulting with Global Talent Pathway in roles assessed as contact with/impact on children or as working with children to have for all countries of citizenship and countries of residence for last 5 years. Only consultant/contractor roles/tasks assessed as nil contact with/nil impact on children are exempt. | Those in positions assessed as contact with or working with children to have for all countries of citizenship and countries of residence for last 5 years |
Working with Children Check | Those whose position is assessed as 'working with children' | Those whose position is assessed as ‘working with children’ | Those whose position is assessed as ‘working with children’ | Those whose position/task is assessed as ‘working with children’ | Those whose position/task is assessed as ‘working with children’ | Those whose position/task is assessed as ‘working with children’ |
Confidentiality Agreement | All | All | All | All requiring access to information Global Talent Pathway would regard as confidential | All requiring access to information Global Talent Pathway would regard as confidential | Not required |
Privacy Agreement | All | All | All | All obtaining access to personal information stored by, or to be gathered in the name of Global Talent Pathway | All obtaining access to personal information stored by, or to be gathered in the name of Global Talent Pathway | Not required |